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D. Conclusion
We sustain respondent’s determination to include $40,347 in
petitioner’s gross income for the audit year, and we hold that
petitioner is not entitled to a deduction for loss of the IBM
sale proceeds of $27,573 as an offset to that income inclusion.
II. Schedule A Itemized Deductions
We must decide whether petitioner is entitled to Schedule A
itemized deductions for the audit year consisting of real estate
taxes of $1,420 and “deductible points” (mortgage interest) of
$10,430. The 1988 return indicates that those amounts relate to
what was, before his incarceration, petitioner’s personal
residence in Fairfax, Virginia.
Petitioner has failed to substantiate his payment, during
1988, of any real property taxes with respect to his personal
residence; and, except for an undated, handwritten listing of
mortgage payments due with respect to various properties,
including his personal residence, and a computer printout which
appears to list mortgage payments due on that residence for
March, April, and May 1992, petitioner has failed to produce any
receipts or other evidence to corroborate his return position
that he made a 1988 payment of “deductible points”. Petitioner
did not claim a deduction for mortgage interest on what he claims
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